3. Statement of Facts
3.1 Overview of the Undergrounding Project
The City has a program authorizing the designation of particular areas for the removal of poles and overhead wires that the City has determined would be better undergrounded.3 All parties agree that the typical reason for such undergrounding is aesthetics. A 1995 agreement between SDG&E and the City is the basis for this program. The City annually reviews and proposes for funding particular underground projects.4 The City created the "30th Street (University Avenue to Olive Street) Underground Utility District" (Underground District) by Resolution R-293141 (May 16, 2000), to allow the relocation underground of a portion of a 138 kV transmission line running overhead along 30th Street. The plan of the Underground District attached to R-293141 is reproduced as Appendix A to this decision. The City found that the formation of the Underground District was exempt from CEQA pursuant to CEQA Guidelines Section 15302(d).5
In September 2000, SDG&E sent a letter informing City staff that SDG&E was changing the undergrounding route shown in Appendix A. Instead of proceeding along 30th Street, a predominantly commercial street where the overhead line ran, the undergrounding would proceed under 29th Street and Dale Street, in a primarily residential area. The new route, SDG&E stated, had more space available for the underground conduit and would be less disruptive to traffic and businesses in the area. This route is reproduced as Appendix B to this decision.6
SDG&E began construction of the Undergrounding Project, approximately 1.4 miles in length, in August 2001 and placed the line into service in April 2002.7 The poles for the previous overhead line along 30th Street were removed by mid-March 2004. Additional undergrounding of the overhead line now along 30th Street is planned. What is referred to as "Phase 2" will continue the undergrounding farther south. The projected route for Phase 2 is attached as Appendix C to this decision.8 Future phases are possible, but plans for them have not yet been developed.
3.2 Construction
The Undergrounding Project consists of the conversion of a portion of an existing overhead 138 kV transmission line that runs north to south through the Golden Hill and North Park areas of San Diego. The underground installation consists of SDG&E's standard double circuit duct bank. This has six, 6-inch conduits placed in two vertical columns. The center four-inch conduit is used for SDG&E's telecommunications system; the two outer columns of conduits, consisting of six conduits, are for high voltage electric cable. Three of these conduits in one column are in use for the electric cables required for the current Undergrounding Project; the vacant ducts in the other column may be used for a future circuit.
3.3 EMF Measurements
Residents in the area of the Undergrounding Project, concerned about possible EMF emissions from the transmission line installed under 29th Street and adjoining streets, have both taken EMF readings themselves and asked SDG&E to send a representative to take readings. Using a gauss meter (the accepted tool for EMF measurement), residents have taken a variety of measurements of EMF levels in the vicinity of the undergrounded line. The average of all the measurements taken 50 feet from the location of the line is between five and six milligauss (MG), with peaks above 10 MG. In one visit to a home on Dale Street with a 50-foot setback from the trench for the underground line, SDG&E personnel obtained readings of approximately 9.5 MG at the front door, with an average indoor level of 7.5 MG. At the request of residents, SDG&E also made measurements at other homes and outdoor locations. Neither CAUSE nor SDG&E was able to quantify the proportion of detected EMF emissions that are a result of the Undergrounding Project. Based on information provided in limited existing studies, average exposures of 7.5 MG are higher than those experienced by most people in the United States.
3 San Diego Municipal Code § 61.0508. See also SDG&E Tariff Rule 20 (July 25, 2002).
4 The City approved the allocation of funds for 30th Street undergrounding from University Avenue to National Street in Resolution R-292225, dated September 27, 1999.
5 Section 15302 provides that a project will be exempt from CEQA if the project
. . . consists of replacement or reconstruction of existing structures and facilities where the new structure will be located on the same site as the structure replaced and will have substantially the same purpose and capacity as the structure replaced, including but not limited to: . . .
(d) Conversion of overhead electric utility distribution system facilities to underground including connection to existing overhead electric utility distribution lines where the surface is restored to the condition existing prior to the undergrounding.
The CEQA Guidelines are found at 14 Cal. Code Reg., sec. 15000 et seq.
6 Provided as Attachment A to the Testimony of William V. Torre (July 20, 2005) (Torre Testimony).
7 Because this complaint was filed within three years of the construction of the Undergrounding Project, it is timely.
8 Provided as Attachment B to Torre Testimony.
